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Claiming industrial citizenship: The struggle for

domestic worker rights in Indonesia

David Jordhus-Lier

To cite this article: David Jordhus-Lier (2017) Claiming industrial citizenship: The struggle for
domestic worker rights in Indonesia, Norsk Geografisk Tidsskrift - Norwegian Journal of Geography,
71:4, 243-252, DOI: 10.1080/00291951.2017.1369453

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 Norsk Geografisk Tidsskrift–Norwegian Journal of Geography, 2017
VOL. 71, NO. 4, 243–252
https://doi.org/10.1080/00291951.2017.1369453

Claiming industrial citizenship: The struggle for domestic worker rights in

Indonesia
David Jordhus-Lier

David Jordhus-Lier, Department of Sociology and Human Geography, University of Oslo, PO Box 1096, Blindern, NO-0317 Oslo

ABSTRACT
The author argues that recent attempts to build a domestic workers’ movement in Indonesia can be
understood as an ongoing and non-linear process driven by claims for industrial citizenship.
Thomas Humphrey Marshall’s concept of industrial citizenship, presented in his historical analysis
of industrial Britain, drew some profound connections between political mobilisation and the
realisation of rights that seemed to resonate with contexts far beyond its (i.e. industrial Britain’s)
Downloaded by [University of Sussex Library] at 08:07 20 September 2017

ARTICLE HISTORY
time and place. Based on a qualitative research project in five Indonesian cities, the author Received 8 September 2016
shows how an embryonic movement has mobilised for legislative recognition of domestic Accepted 16 August 2017
worker rights, and explains why mobilisation has proved difficult. Based on both a
decontextualised and recontextualised reading of the concept of industrial citizenship, the EDITORS
author concludes there are three main reasons for the limited political success of the domestic Kristian Stokke, Catriona
Turner
workers’ movement are identified: a limiting social identity attributed to domestic workers in
Indonesia; the intersectionality of informal domestic work as reflected in the institutions of the KEYWORDS
labour market; and the lack of mutually constitutive scales of organising between the urban domestic workers, Indonesia,
neighbourhoods in which domestic workers live and work and policymaking at the national level. industrial citizenship,
informal work,
intersectionality

Jordhus-Lier, D. 2017. Claiming industrial citizenship: The struggle for domestic worker rights in Indonesia. Norsk
Geografisk Tidsskrift–Norwegian Journal of Geography Vol. 71, 243–252. ISSN 0029-1951.

Introduction
Indonesian domestic workers are taking to the streets,
not in marches by the thousands, but in small groups
of women who carry the personal risk of losing their
jobs by going public with demands for rights at work.
Supported by non-governmental organisations
(NGOs), domestic workers have been trying to organise
themselves politically in cities across Indonesia since the
early 1990s. Since its beginning, one of the central
demands of this embryonic movement has been to
secure formal worker rights and social security. Despite
years of combining local organising activities, alliance-
building and parliamentary lobbyism, domestic workers
in Indonesia have had limited success in securing formal
recognition as workers.
Understanding the political mobilisation as a struggle
for citizenship is in line with how one NGO activist
described the movement of which she was a part: ‘The
domestic worker issue is a woman’s issue, a worker
issue and a human rights issue. Everything relates to
the domestic worker’ (interview, Lita Anggraini,1 3 July
2015). In this article, I argue that the strategies of politi-
cal mobilisation of domestic workers, as well as their still
limited legislative impact, can benefit from a conceptual
discussion of industrial citizenship. To cite Zhang & Lil-
lie (2014, 3), ‘Industrial citizenship, despite the long his-
tory of the term, remains an underdeveloped concept
within citizenship studies’; there are many reasons for
this underdevelopment. Today’s global workforce differs
on several accounts from the workers of 19th century
industrial Britain on whom T.H. Marshall (1992
[1950]) modelled his concept of industrial citizenship.
Moreover, worker organisations such as those that rep-
resent Indonesian domestic workers are often not trade
unions in the classic sense. More recently, while unions
have experienced decline across Europe and North
America, and while academic observers have proposed
alternatives to trade unionism altogether (Waterman
2005; Standing 2009), the concept of industrial rights
might seem archaic and passé.

CONTACT David Jordhus-Lier david.jordhus-lier@sosgeo.uio.no

© 2017 Norwegian Geographical Society
 244 D. Jordhus-Lier
Still, workers claim rights all over the world, in work-
places as well as in political publics. Even under
unfavourable conditions, there are examples of innova-
tive worker organisations in developing countries that
see their membership rising, not falling (Lambert &
Webster 2001). In this article, I argue that the concept
of industrial citizenship can still inform the study of con-
temporary struggles for worker rights.
My argument is based on the experiences of a particu-
lar group of marginalised workers, namely those who
perform paid work in Indonesian homes. According to
a national network of domestic worker organisations in
Indonesia, there are an estimated 10.7 million2 workers
employed in private homes across Indonesia. In 2015,
the majority of the c.6 million international migrants
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working outside Indonesia work as domestic workers
according to the International Federation of Red Cross
and Red Crescent Societies.3 During the course of
2015, a research team that included myelf and two Indo-
nesian researchers4 conducted c.50 interviews with
organisational representatives, domestic workers, acti-
vists and government officials in five Indonesian cities
– Yogyakarta, Jakarta, Medan, Palembang, and Kupang
– as well as holding a focus group discussion with 5–
12 domestic workers in both Yogyakarta and Jakarta.
The argument presented in this article is also based on
the results of research on the domestic workers’ school
in Yogyakarta conducted by Gastaldi (2015).
By analysing the mobilisation of Indonesian domestic
workers through the lens of industrial citizenship, two
objectives are achieved. First, the analysis highlights
some key limitations to an NGO-driven, rights-based
political approach to domestic work in Indonesia. The-
ories of industrial citizenship assume that the realisation
of worker rights rests on the mutually constitutive
dynamics between class-based solidarity and political
mobilisation. This is a useful starting point from which
to understand the obstacles facing domestic workers
and their organisational allies. Second, the case supports
and expands on an existing critique of the concept of
industrial citizenship. I argue that the experiences of
exploited, informal workers in the Global South should
lead us to update and revise industrial citizenship as an
analytical concept, rather than reject it.
However, before presenting a critique of the concept
industrial citizenship, I present a detailed introduction
to the concept. This article starts with a brief introduc-
tion to the original concept as presented by Marshall
(1992 [1950]), and its appropriation and critique by aca-
demic scholarship in recent years. Inspired by Marshall’s
original idea of a mutually reinforcing relationship
between different forms of citizenship, I draw on
Zhang & Lillie’s (2014) distinction between industrial
citizenship as process and industrial citizenship as status.
I favour a process-oriented approach, and use the organ-
ising efforts among domestic workers in Indonesia as a
case to exemplify the merits of a decontextualised and
recontextualised understanding of industrial citizenship.
Industrial citizenship and the struggle for
rights
Industrial citizenship refers to the ability of workers to
organise collectively in the realm of work – from the
workplace to systems of industrial relations – which in
turn may give workers sufficient leverage to enforce
their rights outside the realm of work through, for
example, labour legislation and welfare reforms. As the
concept can be traced back to Marshall’s (1992 [1950])
historical analysis of citizenship and social class, it is
worth revisiting its original interpretation. Marshall
made the now well-known distinction between three
forms of rights: civil, political and social. He also linked
their development throughout the history of capitalism
to three stages, from the emergence of civil rights in
the 18th century, though the expansion of political rights
in the 19th century, and the establishment of social rights
in the national welfare states of the 20th century. The
relationship between capitalism and these categories of
rights is contentious in Marshall’s reading, but not in a
straightforward manner. For example, civil rights are
individual in their nature and correspond well with the
private sale and purchase of labour power at the heart
of capitalist accumulation. By contrast, political rights
are collective in nature and hence counter to the logic
of capitalism. However, political rights were not seen
as a threat until the emergence of social-democratic
labour parties in the twentieth century. This represents
the last phase in Marshall’s account (1992 [1950]),
when citizenship became ‘at war’ with capitalism during
the expansion of social rights.
Marshall argued that one of the main vehicles for
expanding social rights in industrial Britain was trade
unionism. According to him, trade unions broke with
the linear movement from civil, via political, to social
rights. Rather, trade unionism established collective civil
rights – the right to bargaining as a collective unit:
This meant that social progress was being sought
by strengthening civil rights, not by creating social
rights; through the use of contract in the open market,
not through a minimum wage and social security.
[…] [T]he acceptance of collective bargaining was not
simply a natural extension of civil rights; it represented
the transfer of an important process from the political
to the civil sphere of citizenship. (Marshall 1992
[1950], 26)
 Norsk Geografisk Tidsskrift–Norwegian Journal of Geography 245

Hence, Marshall saw industrial citizenship in the form Status-oriented and process-oriented
of a well-organised working class as instrumental in the approaches
securement of broader social rights. Since he formu-
Zhang & Lillie (2014) argue that industrial citizenship, as
lated his theory, the concept of industrial citizenship
an academic concept, can be understood as both a
has met constructive criticism from different quarters.
societal process and a status granted to individuals
Feminist scholars in particular have identified short-
within a territorially defined community. Whereas Mar-
comings in Marshall’s assumptions. Fudge (2005)
shall’s original notion, as presented above, clearly
argues that as industrial citizenship emerged in indus-
described industrial citizenship as a socio-historical pro-
trial Britain, it was premised on the privileged subject
cess, others have since come to use the term to describe a
of ‘the male breadwinner’. This is problematic, because
state (or a desired state) of worker rights protection.
Marshall ‘appears to assume that women will gain their
Fudge (2005, 635) uses Canada as an example to show
entitlements through their husbands, and his concept
how industrial citizenship can be understood as a ‘status
of citizenship clearly takes for granted the unpaid
limiting commodification and conferring rights to influ-
labour of women’ (Zetlin & Whitehouse 2003, 774).
ence terms of employment’. She thus conceives industrial
Given the specific historical and geographical context
citizenship as a status, corresponding to a given level of
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of Marshall’s analysis, one might raise concerns

worker rights protection. As in other Western econom-
about the applicability of the concept to worker
ies, this corresponds well with the employment security
struggles in Indonesia or other developing countries
granted to Canadian male workers during the post-
in the 2010s, given that not all forms of worker organ-
World War II period. However, the decommodification
isation represent a struggle for industrial citizenship.
of work is neither complete nor stable, and Fudge
Such a universal application would dilute the concept
(2005, 643) argues that since 1980, Canadian industrial
of industrial citizenship. Industrial citizenship is not
citizenship has been narrowed due to the ‘combined
an all-encompassing concept suited to explain the poli-
pressures of globalization, deregulation and feminiza-
tics of work in all its breadth. One might be tempted to
tion’. The ascent of a neoliberal ideology, with its univer-
exclude workers in informal employment, such as the
salistic conceptions of civil rights, ran counter to the
situation in which most Indonesian domestic workers
‘distinctive class inflection’ of industrial citizenship
find themselves. Informal work involves issues that
(Fudge 2005, 635). This thinking is in line with that of
transcend a traditional trade union agenda, and in
Aguiar (2006, 451), who argues that individualised rights
the growing literature on informal worker organis-
are ‘increasingly privileged over collective rights’, which
ations (e.g. Brown et al. 2010; Lindell 2010a) it is docu-
means that groups of people who are marginalised in the
mented that the conditions of work are shaped by a
labour market experience ‘incomplete citizenship’ at
range of societal actors, including religious brother-
work.
hoods, saving schemes and product associations. In
Measured as status, the decline of industrial citizen-
this regard, the politics of informal work are often
ship in Western economies serves to complicate further
negotiated without using the language of class or
an already uneven distribution of worker protection
worker rights.
between genders, social groups, industrial sectors and
In this article, I argue that neither geographical area
regions of the world. The unevenness of industrial citi-
(the Global North as opposed to the Global South) nor
zenship creates a variegated landscape of labour market
economic sector (traditional industrial sectors as
regulation between and within world regions, which
opposed to, for example, informal work arrangements)
for many workers represents a motive to migrate in
should determine the applicability of industrial citizen-
search of better employment conditions. Indonesian
ship as an analytical concept. Rather, the defining feature
domestic workers are an illustrative example in this
in Marshall’s account is the active mobilisation of class-
regard. In addition to the rural–urban migration that
based mobilisation strategies and rights-based dis-
many domestic workers are engaged in within Indonesia,
courses. This limitation still leaves ample room for an
the majority of the country’s international migrant
organisational multitude of trade unions, workers’
workers are domestic workers (Yeoh & Huang 1999;
associations, non-governmental organisations and sup-
Rudnyckyj 2004; Silvey 2004). While legal migration
port networks, the presence and influence of which has
might allow certain workers to move into territorial jur-
been documented as far back as 19th century industrial
isdictions with better employment security, illegal labour
Britain (see Lindell 2010b for an overview). This reading
migration deprives workers of their legal status and
of the concept opens for a more dynamic understanding
excludes them from industrial citizenship in both absol-
of industrial citizenship, instead of reducing it to a his-
ute and relative terms (Castles 2011).
torical account.
 246 D. Jordhus-Lier
There are clear advantages to conceiving industrial
citizenship as status. For example, it can serve as an
ideal type for comparative reviews of formal worker
rights between regions and countries as evident in the
databases of the International Labour Organisation
(ILO) (see Caraway 2009 for such a comparison). More-
over, conceiving industrial citizenship as status can be
useful to understand the relative gains and losses that
result from worker mobility (see Ball & Piper 2002; Cas-
tles 2011 for both micro- and macro-approaches). How-
ever, there are also problems with this approach, because
it easily leads to what Somers (1996) appropriately labels
an ‘epistemology of absence’, meaning that a phenom-
enon is explained by what it lacks, instead of by its
observed qualities. This is particularly the case when
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investigating workers in countries outside Europe and
North America. Perhaps this is why industrial citizen-
ship is rarely applied to worker struggles beyond this
particular geographical region in the world economy.
One of the few examples in a Global South context can
be found in Kenny’s (2007) analysis of post-apartheid
workplaces in South Africa. She describes how employ-
ers’ attempts to lobby for regulatory dispensations in
labour law to the detriment of casual workers ‘reinforced
the social imaginary of the full-time, permanent worker
as the subject of “industrial citizenship”‘ (Kenny 2007,
285). While full-time, permanent employment might
be the reality for a small core of industrial and public sec-
tor workers in certain industrialising developing
countries, such as South Africa or Brazil, most workers
in the world are very far from enjoying the level of
employment protection and social security associated
with industrial citizenship. Hence, a status-oriented
approach holds limited relevance beyond a particular
Western historical experience.
Alternatively, if the focus is on industrial citizenship as
a process, the implications are different. Marshall’s orig-
inal use of the term contained a sophisticated under-
standing of how different sets of rights developed in a
mutually constitutive sequence, and how social citizen-
ship (e.g. social security and welfare rights) was the result
of political struggle and worker mobilisation.
Approaching industrial citizenship as a process is
potentially a more open approach to the concept, as
workers politicise their conditions of work in every cor-
ner of the world, and often through a language of rights.
As this article is concerned with understanding the pol-
itical mobilisation of a group of workers who enjoy very
limited worker rights, it seems more suitable to adopt a
process-oriented approach to industrial citizenship.
The organisations of domestic workers in Indonesia do
engage in rights-based mobilisation, not only at work
but also in the political sphere. Hence, Marshall’s
concept of industrial citizenship can be used to explore
the interconnections between worker organisation and
the realisation of citizenship rights. In particular, Mar-
shall’s insistence on worker organisation as a decisive
factor in enabling the translation of political and collec-
tive civil rights into social rights might be important
here.
However, even a process-oriented approach to worker
mobilisation could lead to Eurocentrism (Cabrera 2008),
whereby empirical cases are studied to ‘explain the
absence of an expected outcome’ (Somers 1996, 180),
such as collective bargaining or tripartite social dialogue.
As Zhang & Lillie (2014, 13) aptly state, ‘we must be cau-
tious about the teleological and unidirectional reading of
the development of citizenship rights’. The struggle for
rights at work does not always take the form of trade
unionism, nor is it necessarily motivated by a clear
goal of building a socialist or social democratic society.
Hence, to facilitate a contemporary use of industrial
citizenship in accordance with Marshall’s original idea,
we need to decontextualise and recontextualise the pro-
cesses of citizenship formation. If we were to manage to
do so, we would open up the concept of industrial citi-
zenship to alternative trajectories and other mobilising
identities. In the remainder of this article, I use domestic
workers’ organisations in Indonesia as a case to illustrate
the usefulness, but arguably also some of shortcomings,
of the concept in a contemporary labour struggle.
Mobilising for domestic worker rights in
Indonesia
The end of the oppressive New Order regime in 1998 sig-
nalled new opportunities for industrial citizenship in
Indonesia. In the phase immediately after the fall of Pre-
sident Suharto, labour legislation was put in place that
guaranteed organisational rights and the number of
independent trade unions increased dramatically (Ford
2000). Expanded industrial rights were a result of inter-
national pressure, as well as pressure from domestic
trade unions. However, this initial extension of rights
was followed by another process of labour law reform
whereby ‘flexibilisation’ and outsourcing were intro-
duced to deal with the effects of the Asian financial crisis
in the late 1990s. This paved the way for the Manpower
Act of 2003, which stipulated the essential rights and
obligations of employers and workers in Indonesia (Sur-
yomengglo 2009), and was only passed due to sustained
political pressure from the newly established trade
unions. However, the country’s millions of domestic
workers are excluded from the definition of workers
and workplaces under the current interpretation of the
law.

The political mobilisation of domestic workers dates
back to the activities of women activists in Yogyakarta
in the early 1990s, and has since led to the formation
of local unions in several cities and a national network
for domestic workers’ rights, Jala PRT. Since 2004, Jala
PRT has lobbied the Indonesian parliament (Dewan Per-
wakilan Rakyat) to pass a Domestic Workers Protection
Bill that would end the exclusion of domestic workers
from formal worker rights. Despite the activism of Jala
PRT, which included a high-profile hunger strike in
2014 and the involvement of international organisations
such as the ILO, the bill has been dropped from the list of
legislative priorities (prolegnas) several times by Indone-
sian elected politicians. Moreover, despite having one of
the world’s largest domestic worker workforces, Indone-
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sia has yet to ratify ILO Convention 189 (dating from
2011) concerning decent work for domestic workers.
A ministerial regulation in 2015 (Permenaker No. 2/
2015) compensated to some extent for the legal vacuum
surrounding domestic work by requiring domestic
employers and employees to formalise their agreement
in a written contract (Austin 2016). While the regulation
was welcomed by activists interviewed in the research
(see endnote 4), it was also criticised for relegating the
politics of domestic work to the private sphere (cf. Silvey
2004).
When examining how organisations representing
domestic workers in Indonesia have engaged with these
political and legislative processes, I would argue that
this case highlights three challenges that have been insuf-
ficiently discussed in the literature on industrial citizen-
ship: the constraints of existing social identities, the
intersectionality of informal domestic work, and the pro-
blem of scale. While each of these challenges is structural
in nature, as they are rooted in deep-seated cultural prac-
tices, they also appear as political and institutional
obstacles for those attempting to organise Indonesian
domestic workers. In the following sections, I discuss
these challenges in turn, as well as the responses they
have drawn from domestic workers and their
representatives.
Challenging social identity through collective
identity construction
Zhang & Lillie (2014, 5) argue that the emergence of
worker mobilisation requires the development of
class capacities and bonds of solidarity through ‘shared
symbols, networks, organizations’, all of which they
see as on the wane in many Western countries. In
developing countries such as Indonesia, this class-
based solidarity has never been established beyond a
limited group of workers in the industrial sectors.
Norsk Geografisk Tidsskrift–Norwegian Journal of Geography 247
Workers in both of these contexts are therefore forced
to base their mobilisation on other identities than
those that served as the basis for industrial citizenship
in 20th century Europe.
Questions of solidarity and identity construction are
critical to the continued relevance of industrial citizen-
ship, but are not discussed explicitly in Marshall’s
(1995 [1950]) original account. If bonds of solidarity
and a common identity as workers do not exist prior
to mobilisation, they must be created through mobilis-
ation. Identity, solidarity and political mobilisation can
thus be seen to stand in a mutually constitutive relation-
ship to each other, and as a precondition for the realis-
ation of industrial citizenship. Mapping the
geographies of industrial citizenship is therefore not
only limited to documenting its end product – in the
form of social and economic rights – but also implies
studying concrete attempts to construct worker identi-
ties, to establish alliances between different groups of
workers, and to mobilise politically. Political mobilis-
ation will always seek to maintain a firm foundation in
social categories and identities from which they draw
their members (cf. Cox 1998).
A fruitful analogy is arguably to think of industrial
citizenship as an imagined community (cf. Anderson
2006) of common interest that is continuously in need
of being affirmed and reproduced. However, all ima-
gined communities entail processes of exclusion and
inclusion. Hence, for many workers worldwide, particu-
larly marginalised groups such as informal workers,
transnational migrants and domestic workers, the
struggle for industrial citizenship is also a struggle to
be included in existing class categories or to create new
ones. Processes of collective identity construction are
therefore an important part of struggles for industrial
citizenship (Melucci 1995; Kelly 1998).
The social identity attributed to domestic workers in
Indonesia represents a formidable obstacle to collective
identity construction. Domestic workers are still seen
as making limited contributions to society, because
their work is not recognised as producing economic
value (Weix 2000; Gastaldi 2015). Hence, they are nor-
mally referred to as domestic helpers (pembantu
rumah tangga) rather than as domestic workers (pekerja
rumah tangga). This social identity is borne out of the
semi-feudal and familial work arrangements that tra-
ditionally have governed domestic work in Indonesia.
The fact that Indonesian domestic workers are women
working in a patriarchal society serves to deepen their
social exclusion. This feeds into a politics of intersection-
ality (cf. Bernardino-Costa 2014), where their role as
outsiders in the public domain is cemented by their sta-
tus as poor, as migrants, and as women, whereas their
 248 D. Jordhus-Lier
role as insiders in the private domain excludes them
from acting as political subjects:
Interviewer: Have you ever asked her how
she describes herself?
Employer in Kupang: No, we don’t ask things like
that. We don’t even introduce
her as a ‘helper’ (pembantu),
we introduce her as ‘the one
who helps us’. More polite.
These perceptions were not limited to the interviewed
employer, as domestic workers encounter the same social
identity in their own social networks:
Some of our own family members don’t think that we
are workers. We get less respect than other family mem-
bers who work as factory workers. Society doesn’t think
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domestic workers exist. We are just a complement at
neighbourhood meetings. (Member of a domestic
workers’ union in Yogyakarta)
Given the social exclusion that members of this group
experience in their own communities, it not surprising
that Indonesian society fails to include this category of
worker in its legal framework and political practice:
We want recognition from the state as workers, not as
maids, and that as domestic workers we are not despised
or viewed as incapable. (Leader of a domestic workers’
union in Jakarta)
Domestic workers’ social identity more often frames
them as subjects in need of protection than as social
actors with political agency. In two of the Indonesian
cities where we conducted interviews, Palembang and
Kupang, the issue of domestic workers rights was thus
limited to campaigns by middle-class women’s organis-
ations relating to domestic abuse and human trafficking.
This raises an important strategic dilemma in Indonesian
civil society that has also been recognised in Varghese’s
(2006) analysis of domestic workers in the USA: Does
mobilising on behalf of domestic workers risk margina-
lising mobilisation by domestic workers? Related to
this, it is worth recalling that Marshall (1992 [1950])
did not see social rights as a result of benevolent ruling
elites but rather as the outcome of a mobilised working
class. As Zhang & Lillie (2014, 5) aptly state, ‘where
social citizenship reflects working-class power, industrial
citizenship is the source of that power’.
The mobilisation of Indonesian domestic workers since
the 1990s can be understood as an attempt to challenge
the social identity described above through a process of
collective identity construction. A collective identity serves
two important purposes. First, it builds solidarity within
the group. The establishment of domestic workers
schools (Sekolah PRT) in Yogyakarta and Jakarta has
been important in this respect (Gastaldi 2015). In the
schools, trained activists and domestic workers meet to
define what it means to be a ‘domestic worker’ together:
For every meeting we hold, the more we get our mind
clear about our rights as domestic workers. […] Thanks
to this organisation, my friends are now able to stand up
for themselves. We didn’t have the guts before. Myself
included. (Leader of a domestic workers’ union in
Jakarta)
I used to be a helper, but now I am a worker. (Member of
a domestic workers’ union in Jakarta)
When I first met [the union] I was hopeless, had many
problems. But joining up with other members gave me
the spirit not to give up. Now I know I’m not alone.
We have a solidarity network with many activities.
(Member of a domestic workers’ union in Yogyakarta)
Apart from Sekolah PRT, also worker associations and
credit schemes are available to domestic workers in
Yogyakarta, Jakarta, Medan and Semarang. These groups
offer women a community in which they can experience
worker solidarity and develop their own sense of empow-
erment. Second, collective identity construction serves to
reconfigure the relationship between domestic workers
and society. In the slogans publically displayed on pla-
cards and T-shirts, domestic workers are explicitly por-
trayed as workers. This is also very visible in the
language used by activists in media. In a culture in
which women are predominantly referred to as domestic
helpers, maids or even servants (Weix 2000; ILO 2006),
even the act of referring to themselves as domestic
workers (pekerja rumah tangga, abbreviated as PRT)
represents a political act. The acronym PRT has become
well known in Indonesian public discourse. A quote
from a provincial government official serves to illustrate
the paternalistic conception of domestic work:
[S]uddenly they are called ‘workers’ [pekerja]? Maybe
they do it to elevate the housemaids’ dignity a little. It
is not a problem for us about who changed the term,
right?
Even though the number of organised workers is still
limited, it is clear that this emerging alternative collective
identity is already making a mark on official discourse.
However, amidst this rhetorical shift, the institutions
that govern working life have proved hard to alter.
From private and informal to public and formal?
One reason why industrial citizenship has been geo-
graphically associated with Western Europe and North-
ern America is the assumption that it corresponds to a
boundary between formal and informal employment.
Formal employment took on very different expressions
during the development of post-war Keynesian welfare

states than they do in most countries in today (Standing
2009). Many of the processes that led from industrial
citizenship to social citizenship in Europe entailed the
formalisation of the standard employment relationship,
which in turn guaranteed extensive welfare provisions.
When understood in this way, informal employment
arrangements in developing countries might appear as
the antipode of industrial citizenship.
If we are to maintain our commitment to a process-
oriented understanding of industrial citizenship, we
would be ill-advised to neglect the possibility of mean-
ingful claims for rights and recognition outside the
realm of standard formal employment. Moreover, such
claims do not have to be met with the same trajectory
of formalisation that workers in industrial and public
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sectors have pursued in the past. While the literature
on labour regimes in the Global South has rarely
employed the theoretical lens of industrial citizenship,
the exclusion from formal labour regulation has been
identified as a key challenge for very different subjects:
workers in special economic zones (Jenkins 2015); street
vendors and other informal workers forced into self-
employment (Lindell 2010a); and those who work within
the confines of private homes (see Ally 2010 for an analy-
sis of South African domestic workers).
Industrial citizenship has always been exclusive in
nature, excluding particular groups and being confined
to particular spaces. Even more than in countries such
as South Africa (cf. Ally 2010), Indonesian domestic
workers have found the boundary between home and
work – between what is perceived as the productive
and reproductive spheres of society – hard to cross
(Weix 2000). However, this boundary is not static.
Since the period in which President Suharto was in
office, urbanisation and a growing middle-class have
led to an increasing commodification of domestic labour.
Even in cases in which the arrangements remain infor-
mal, urban domestic work is no longer confined to kin-
ship networks and constitutes a de facto employment
relationship between an employer and an employee.
This has opened for attempts to establish a collective
‘domestic worker’ identity by union activists. However,
the Indonesian state still represents a main hurdle for
these attempts, by refusing to accept domestic work as
a public concern, and instead confining it to the intimate
politics of the home (Silvey 2004).
To domestic workers, the formal–informal divide also
entails renegotiating multiple roles and relationships
with their employers, as well as with other workers.
This intersectionality of domestic work is reflected in
the exclusion of domestic workers from the institutions
of industrial relations. Domestic workers in Indonesia
lack a national trade union in the formal sense as in
Norsk Geografisk Tidsskrift–Norwegian Journal of Geography 249
most other countries. For informal workers, levels of
unionisation are extremely low among domestic employ-
ees, and it is only recently that some of the major trade
unions have attempted to organise informal workers in
a separate organisation. To compensate for this, the
national network Jala PRT cooperates loosely with
trade union federations on certain lobby activities. How-
ever, building trust between trade unions and the organ-
isations is a painstaking exercise, as trade union leaders
and many of their members themselves employ domestic
workers.
The dilemma of the employer’s role is manifested also
on the other side of the negotiation table. Because
employers are the heads of private households, there
are no employers’ associations or interest organisations
dedicated to those who employ workers in their own
households. This does not mean that the interests of
the employers are not channelled into the political pro-
cess, albeit in an informal manner. Politicians, employ-
ers, trade union leaders and NGO representatives are
all likely to be employers of domestic workers in Indone-
sia, and this spurred the leader of Jala PRT to comment
that ‘they are all the employer side’ (interview, Lita
Anggraini, 30 June 2015). This is an often-overlooked
aspect of intersectionality underlying the politics of
domestic work. The hesitance of various actors to
embrace the extension of minimum wage regulation to
domestic workers is illustrative of this fact, and was
repeatedly expressed during interviews with the author
(Jordhus-Lier & Prabawati in press).
The problem of scale
In addition to having to break loose from their social
identity and meeting the problem of intersectionality in
industrial relations, a third challenge for organised dom-
estic workers has been to agree on where to seek political
change. The domestic workers’ movement in Indonesia
is currently drawn between national legislative change
as the main goal, and a small and embryonic group of
membership-based organisations focused on recruiting
and servicing members. Whereas the legislative cam-
paign is coordinated by a network of NGO activists at
the national scale, the latter group views the metropoli-
tan area (or even the neighbourhood) as their scale of
organisation. The politics of domestic work as a problem
of scale was conceived by Silvey (2004) in her study of
Indonesian domestic workers in Saudi Arabia. She
argued that labour migrants’ individual strategies of
migration and their collective strategies of transnational-
ism (e.g. remittances) was a form of scalar politics.
Through their transnationalism, domestic workers have
broken out of a particular construction of the household
 250 D. Jordhus-Lier
scale in Indonesia where it is simultaneously seen as
‘foundational to the nation’ and as a workplace beyond
the scope of state jurisdiction (Silvey 2004, 150). By
using the language of industrial citizenship, nuance can
be added to the problem of scale by identifying a mis-
match between a national scale of political activism
and the local scales of organising among domestic
workers working in Indonesia.
The growing presence of the domestic workers’ move-
ment in a national political space has been strengthened
by the alliance-building between Jala PRT and various
actors in civil society. Since emerging from the broader
women’s movement in Indonesia, activists in Jala PRT
have maintained close ties with women’s groups. They
have also had an active international engagement as
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part of the International Domestic Workers Federation
(IDWF) and other transnational activist networks.
Often, such international NGOs employ a rights-based
discourse with a focus on strengthening legal protection
at the national scale. However, these actors are also faced
with the above-mentioned dilemmas of intersectionality
and institutional exclusion. The ‘Decent Work’ agenda of
the ILO is a good example, as it acknowledges the politi-
cal character of worker rights through championing ILO
Conventions 87 and 98 on the right to organise and to
engage in collective bargaining, yet its main efforts
remain top-down, geared at compelling states to commit
to formal agreements guaranteeing rights at work, social
security and tripartite social dialogue. As described
above, the ideal of tripartite social dialogue as stated in
the ILO’s ‘Decent Work’ agenda appears far-fetched
for Indonesian domestic workers.
Thus, Indonesian domestic workers are not yet rep-
resented by leaders with a background in domestic
work at the national scale (what Pitkin 1967 labels
‘descriptive representation’). Moreover, they are unable
to sanction their demands for social rights through act-
ing as collective actors in the labour market (e.g. in the
form of industrial action). While the organising efforts
of Jala PRT range from relatively well-established unions
in Yogyakarta to younger, emergent organisations in
Jakarta and Semarang (Gastaldi 2015), a crucial chal-
lenge for this movement is how to connect its activism
at a national scale with a strategy of establishing dom-
estic workers’ unions across Indonesian cities.
Lessons from the discussion of industrial citizenship
can help to explain why a liberal discourse of citizenship,
in which socio-economic rights are only granted the role
of a secondary accompaniment to civil and political
rights (cf. Jones & Stokke 2005), has proved insufficient.
Attempts to enforce socio-economic rights from above
are often less effective than struggles that substantiate
their mobilisation through worker mobilisation (cf.
Marshall 1992 [1950]). Policies and legal protection tar-
geting domestic workers in Indonesia are predominantly
anchored in the national level. Currently, there is a lack
of mutual benefit between these national lobby efforts
and the embryonic organising activities in local urban
communities across Indonesia. Drawing on the scalar
language of Cox (1998), the Indonesian domestic
workers’ movement suffers from a disarticulation
between the workers’ ‘spaces of dependence’ – which
refers to the privatised workplaces and local associational
life where they live and work – and the national legisla-
tive process that they have identified as their ‘space of
engagement’.
A further spatial dilemma facing the domestic
workers’ movement is the mobile nature of the domestic
labour workforce. Millions of Indonesian workers work
abroad, many of them in the Middle East and in Asian
megacities such as Singapore and Hong Kong. While
domestic workers abroad experience ‘triple exclusion’
from citizenship in their host country, due to being
female, foreign and working in private homes, there
are also examples of attempts to claim citizenship
through the establishment of social organisations and
interest groups (Yeoh & Huang 1999). The level of inter-
national mobility among Indonesian domestic workers is
also likely to impact on claims for citizenship at home.
The future prospects of working abroad attracts many
Indonesian domestic workers and functions as a disin-
centive to invest long-term in organisational efforts in
their current place of work. Many interviewed workers
had alternated between work locations overseas and
employers in Indonesia throughout their careers, mean-
ing that the social basis for unionising workers in ‘transit
ports’ such as Kupang or Medan was fluid and unstable.
Conclusions
Struggles for worker rights such as the attempts to build a
domestic workers’ movement in Indonesia can be under-
stood as an ongoing and non-linear process driven by
claims for industrial citizenship. Indonesian domestic
workers’ organisations and their national network, Jala
PRT, have articulated a clear political goal – the realisation
of social rights in the national legislative assembly. How-
ever, success in this political arena hinges on the concomi-
tant creation of a collective domestic worker identity,
meaningful access to the civil society institutions regulat-
ing industrial relations, and effective political mobilis-
ation. Despite years of committed activism, the
movement has yet to see fundamental legislative reform.
However, as Austin has noted in an unpublished
manuscript, one should not be content with simply ask-
ing why Jala PRT has not achieved greater political

success.5 A one-sided focus on the structural limitations
to industrial citizenship in Indonesia reduces the analyti-
cal significance of this case. Understood as a process, not
an end state, industrial citizenship can also inform an
actor-centred analysis of political mobilisation strategies.
Even though the goal of political recognition has still not
been achieved, the organisations united under the Jala
PRT umbrella seem to be well aware of the critical con-
nections between identity construction, class-based soli-
darity and political mobilisation.
Industrial citizenship, as conceived by Marshall (1992
[1950]) in his seminal essay ‘Social citizenship and class’,
was never intended to be a universal concept, but rather
based on a concrete historical analysis of industrial
Britain. Still, it drew some profound connections
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between political mobilisation and the realisation of
socio-economic rights that seem to resonate with con-
texts far beyond the time and place of his analysis.
What could be argued as universal is that wherever
and by whoever work is undertaken, it can be politicised
and expressed by collective actors. In acknowledging
important criticisms of the concept, particularly regard-
ing its blindness for identity construction and the inter-
sectionality of informal work, I have attempted to
demonstrate in this article the continued relevance of
industrial citizenship in today’s world of work. Even
though domestic NGOs and international development
organisations have been eager to promote a rights dis-
course in support of Indonesian domestic workers, and
can claim some successes as a result, substantial realis-
ation of rights for domestic workers still rests on the
active mobilisation of those whose working lives are at
stake.
Notes
1. Coordinator of the Indonesian National Network for
Domestic Workers Advocacy (Jala PRT, an NGO
network)
2. The estimate was made by a spokesperson for Jala PRT
in official statements and by Lita Anggraini during her
interviews with The Jakarta Post on several occasions
(e.g. Ramadhani 2016).
3. Source: ‘Statistics on labor migration within the Asia-
Pacific region’, http://www.ifrc.org/Global/Documents/
Asia-pacific/201505/Map_Infographic.pdf (accessed 9
June 2017).
4. Fieldwork in Palembang was carried out by Ade Indriani
Zuchri, in Kupang and Jakarta by Debbie Prabawati and
David Jordhus-Lier and in Medan and Yogyakarta by
Debbie Prabawati.
5. Unpublished manuscript written by M. Austin, titled
‘Discourses of the domestic: Towards an Indonesian
domestic workers’ bill?’ (M. Austin, personal communi-
cation 2015).
Norsk Geografisk Tidsskrift–Norwegian Journal of Geography 251
References
Aguiar, L.L.M. 2006. Janitors and sweatshop citizenship in
Canada. Antipode 38, 440–461.
Ally, S. 2010. From Servants to Workers: South African
Domestic Workers and the Democratic State. Scottsville,
South Africa: University of KwaZulu-Natal Press.
Anderson, B. 2006. Imagined Communities: Reflections on the
Origin and Spread of Nationalism. London: Verso Books.
Austin, M. 2016. Defending Indonesia’s migrant domestic
workers. Berenschot, W., Schulte Nordholt, H. & Bakker,
L. (eds.) Citizenship and Democratization in Southeast
Asia, 265–288. PA Leiden: Brill Open.
Ball, R. & Piper, N. 2002. Globalisation and regulation of citi-
zenship—Filipino migrant workers in Japan. Political
Geography 21, 1013–1034.
Bernardino-Costa, J. 2014. Intersectionality and female dom-
estic workers’ unions in Brazil. Women’s Studies
International Forum 46, 72–80.
Brown, A., Lyons, M. & Dankoco, I. 2010. Street traders and
the emerging spaces for urban voice and citizenship in
African cities. Urban Studies 47, 666–683.
Cabrera, M.A. 2008. A critique of ethnocentrism and the crisis
of modernity. History and Theory 47, 607–616.
Caraway, T. 2009. Labor rights in East Asia: Progress or
regress? Journal of East Asian Studies 9, 153–186.
Castles, S. 2011. Migration, crisis and the global labour market.
Globalizations 8, 311–324.
Cox, K. 1998. Spaces of dependence, spaces of engagement and
the politics of scale, or: Looking for local politics. Political
Geography 17, 1–23.
Ford, M. 2000 Indonesian trade union developments since the
fall of Suharto. Labour and Management in Development 1.
Fudge, J. 2005. After industrial citizenship: Market citizenship
or citizenship at work? Relations Industrielles/Industrial
Relations 60, 631–656.
Gastaldi, M. 2015. Domestic Workers Organisation as a Tool to
Reduce Social Exclusion: The Case of Domestic Workers
Organisation in Java. Master’s thesis. Bruxelles: Universite
Libre de Bruxelles.
ILO. 2006. The Regulation of Domestic Workers in Indonesia:
Current Laws, International Standards and Best Practice.
http://www.ilo.org/wcmsp5/groups/public/@ed_norm/@
declaration/documents/publication/wcms_decl_wp_26_en.
pdf (accessed 9 June 2017).
Jenkins, J. 2015. The significance of grass-roots organizing in
the garment and electrical value chains of Southern India.
Newsome, K., Taylor, P., Bair, J. & Rainnie, A. (eds.)
Putting Labour in its Place: Labour Process Analysis and
Global Value Chains, 195–212. London: Palgrave.
Jones, P. & Stokke, K. (eds.) 2005. Democratising Development:
The Politics of Socio-economic Rights in South Africa.
Leiden: Martinus Nijhoff.
Jordhus-Lier, D. & Prabawati, D. In press. Mobilities and mor-
alities of domestic work in Indonesian cities. Jonas, A.E.G.,
Miller, B., Ward, K. & Wilson, D. The Routledge Handbook
on Spaces of Urban Politics. London: Routledge.
Kelly, J. 1998. Rethinking Industrial Relations: Mobilisation,
Collectivism and Long Waves. London: Routledge.
Kenny, B. 2007. Claiming workplace citizenship: ‘Worker’ legacies,
collective identities and divided loyalties of South African con-
tingent retail workers. Qualitative Sociology 30, 481–500.
 252 D. Jordhus-Lier
Lambert, R. & Webster, E. 2001. Southern unionism and the
new labour internationalism. Antipode 33, 337–362.
Lindell, I. 2010a. Informality and collective organising:
Identities, alliances and transnational activism in Africa.
Third World Quarterly 31, 207–222.
Lindell, I. (ed.) 2010b. Africa’s Informal Workers: Collective
Agency, Alliances and Transnational Organizing in Urban
Africa. London: Zed Books.
Marshall, T.H. 1992 [1950]. Citizenship and social class.
Marshall, T.H. & Bottomore, T. (eds.) Citizenship and
Social Class, 1–54. London: Pluto Press.
Melucci, A. 1995. The process of collective identity. Johnston,
H. & Klandermans, B. Social Movements and Culture, 41–
63. Minneapolis: University of Minnesota Press.
Pitkin, H. 1967. The Concept of Representation. Berkeley, CA:
University of California Press.
Ramadhani, N.F. 2016. Domestic workers plead for protection.
The Jakarta Post, 15 June 2016. https://www.pressreader.
Downloaded by [University of Sussex Library] at 08:07 20 September 2017
com/indonesia/the-jakarta-post/20160615/281565175041670
(accessed August 2017).
Rudnyckyj, D. 2004. Technologies of servitude:
Governmentality and Indonesian transnational labor
migration. Anthropological Quarterly 77, 407–434.
Silvey, R. 2004. Transnational migration and the gender
politics of scale: Indonesian domestic workers in
Saudi. Singapore Journal of Tropical Geography 25,
141–155.
Somers, M.R. 1996. Class formation and capitalism: A second
look at a classic. European Journal of Sociology 37, 180–202.
Standing, G. 2009. Work after Globalization: Building
Occupational Citizenship. Cheltenham: Edward Elgar.
Suryomengglo, J. 2009. Labour, politics and the law: A legal-
political analysis of Indonesia’s Labour Law Reform
Program. Labour and Management in Development 9, 1–16.
Varghese, L. 2006. Constructing a worker identity class,
experience, and organizing in Workers’ Awaaz. Cultural
Dynamics 18, 189–211.
Waterman, P. 2005. The forward march of labour (and
unions?) recommenced: Reflections on an emancipatory
labour internationalism and international labour studies.
Antipode 37, 208–218.
Weix, G.G. 2000. Inside the home and outside the family: The
domestic estrangement of Javanese servants. Adams, K.M.
& Dickey, S. (eds.) Home and Hegemony: Domestic Service
and Identity politics in South and Southeast Asia, 137–156.
Ann Arbor, MI: University of Michigan Press.
Yeoh, B.S.A. & Huang, S. 1999. Spaces at the margins: Migrant
domestic workers and the development of civil society in
Singapore. Environment and Planning A 31, 1149–1167.
Zetlin, D. & Whitehouse, G. 2003. Gendering industrial citi-
zenship. British Journal of Industrial Relations 41, 773–788.
Zhang, C. & Lillie, N. 2014. Industrial citizenship, cosmopoli-
tanism and European integration. European Journal of
Social Theory 18, 93–111.